RBI regulations for mandating Legal Entity Identifier in India (2019 extensions update)

RBI (Reserve Bank of India) has mandated the use of LEI for large corporate borrowers and use of LEI in non-derivative markets. RBI hopes to achieve better quality and accuracy for monitoring the health of the financial system. It also hopes to achieve better managed risk in the markets. Therefore the RBI has mandated the use of LEI for the following markets and entities. 

LEI for large corporate borrowers

Banks are required to ask for an LEI from all large corporate borrowers. RBI has implemented a schedule to enforce the regulation in a phased manner. If the large corporate borrowers fail to provide an LEI it’s credit facilities shall not be renewed or new credit will not be offered. 

RBI also encourages to require an LEI from the parent entities, partner entities and subsidiaries of the large corporate borrowers. 

The schedule for implementing LEI regulations to borrowers:

Total Exposure to SCBs To be completed by
₹ 1000 crore and above Mar 31, 2018
Between ₹ 500 crore and ₹ 1000 crore Jun 30, 2018
Between ₹ 100 crore and ₹ 500 crore Mar 31, 2019
Between ₹ 50 crore and ₹ 100 crore Dec 31, 2019

LEI in non-derivative markets

RBI has mandated the use of LEI in the markets regulated by RBI. All participants, other than private individuals, transacting in the markets regulated by RBI shall obtain the LEI in the given schedule below:

  1. Government securities market
  2. Money market -markets for any instrument with a maturity of one year or less)
  3. Non derivative forex markets (settlement of instruments before the spot date)

If the entity fails to receive an LEI before the due date, they can not transact in these financial markets. Neither has an issuer, investor or seller or buyer. 

Schedule for implementation (2019 update – RBI has updated and extended the deadline as following):

Phase Net Worth of Entities Current Deadline Extended Deadline
Phase I above Rs.10000 million April 30, 2019 December 31, 2019
Phase II between Rs.2000 million and Rs 10000 million August 31, 2019 December 31, 2019
Phase III up to Rs.2000 million March 31, 2020 March 31, 2020


All inter-bank non-derivative forex transactions are subjected for an LEI. Non-derivative forex transactions with clients shall be under the LEI requirement if the amount of the transaction is equal or exceeds 1 Million USD or it’s equivalent. 

More about the RBI regulation can be found from their statement.